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Clickstream Corp.

8549 Wilshire Boulevard, Suite 2181

Beverly Hills, CA 90211

August 26, 2021

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Washington, D.C. 20549

Attention: Matthew Derby, Esq.

    Re:
    Clickstream Corp.

    Amendment No. 6 to Offering Statement on Form 1-A

    Filed August 9, 2021

    File No. 024-11475

Ladies and Gentlemen:

By letter dated August 19, 2021, the staff
(the “Staff”) of the Securities and Exchange Commission (the “Commission”) provided Clickstream Corp. (the “Company”)
with comments on the Company’s Amendment No. 6 to Offering Statement on Form 1-A, described above.

This letter contains the Company’s responses to
the Staff’s comments. The numbered responses and the headings set forth below correspond to the numbered comments and headings in
the Staff’s letter to the Offering Statement.

Amendment No. 6 to Form 1-A filed August 9, 2021

Dilution, page 14

 1. We
note your response to prior comment 1. Please explain further why have included the investment in Winners and the option to acquire common
shares of Winner in your total intangible assets, or revise your dilution calculations accordingly.

COMPANY’S RESPONSE

The Company defines
net tangible assets as total assets less intangible assets, less all liabilities. Based upon this definition we have calculated net tangible
worth of $2,368,000 as follows (as revised we have removed as a deduction from our prior calculation the intangible asset portion representing
the amount for Winners Inc’s investment of $297,000 and option of $100,000):

Securities and Exchange Commission

Division of Corporation Finance

Attention: Matthew Derby, Esq.

Page 2

    Net Tangible Assets

    Current assets
    $ 3,055,000

    Non-current assets
      525,000

    Total assets
    $ 3,580,000

    Less:

    Current liabilities
    $ 1,034,000

    Par value of preferred stock (temporary equity)
      50,000

    Intangible assets - intellectual property
      128,000

    Total  liabilities
    $ 1,212,000

    Net tangible worth
    $ 2,368,000

The dilution table has been updated
to reflect this change.

Related Party Transactions, page 28

 2. We
note your response to prior comment 2. Please address the following as it relates to your Related Party Transactions:

 ● Revise
                                            to include a discussion of Winners 10 for 1 forward split and the resulting post-split 5.0
                                            million shares now held by the company.

 ● Revise
                                            Notes B on page 29 to correct the value and resulting gain for your Investment in Winners
                                            at and for the period ended March 31, 2021.

 ● Revise
                                            Note C to correct the value of the option to acquire common shares of Winners at March 31,
                                            2021 to $100,000 and remove your discussion in the Note regarding the value of the investment
                                            in Winners.

 ● Revise
                                            Note C to disclose that the option to exercise common shares of Winners has been further
                                            extended to August 31, 2021.

COMPANY’S RESPONSE

The following revisions
have been made:

 ● Discussion
                                            of 10 for 1 forward split of Winners, Inc and resulting post-split 5,000,000 shares has been
                                            included in Note B on page 29,

 ● Revised
                         Note B on page 29 to correct the value and resulting gain/loss on investment for the period ended March 31,
                         2021,

 ● Revised
                         Note C to report only the option of $100,000 while removing reference of the investment in Winners.

 ● Revised
                         Note C regarding the extension of the option to August 31, 2021.

Securities and Exchange Commission

Division of Corporation Finance

Attention: Matthew Derby, Esq.

Page 3

Note 5. Acquisition of Nebula Software
Corp. (Asset Purchase), page 58

 3. You state in response to prior comment 3 that Note 5 has been amended
to include disclosures provided in your response, however, no such revisions are noted in the filing. Please revise as previously requested.

COMPANY’S RESPONSE

We have revised Notes
to include the applicable disclosure.

If you have any questions regarding this
response, please direct them to our counsel David Ficksman at 310-789-1290 or dficksman@troygould.com.

    Sincerely,

    Clickstream Corp.

    /s/ Frank Magliochetti

    By Frank Magliochetti,

    Chief Executive Officer

cc:	           David L. Ficksman